Policy för personuppgifter
Privacy Statement Summary
This privacy statement explains what information we gather about you, what we use that information for and who we give that information to. It also sets out your rights in relation to your information and who you can contact for more information or queries.
Who this privacy statement applies to and what it covers?
This privacy statement applies to Deloitte Sweden AB with registered office address at Rehnsgatan 11, Stockholm, and the entities we own or control (“Deloitte”, “we”, “us” or “our”). We are committed to protecting your privacy and handling your information in an open and transparent manner. This privacy statement sets out how we will collect, handle, store and protect information about you when:
- providing services to you or our clients
- you use “our Website” or
- performing any other activities that form part of the operation of our business.
When we refer to “our Website” or “this Website” in this policy we mean the specific webpages of deloitte.com designated as Deloitte Sweden.
Deloitte.com is comprised of various global, country, regional and practice specific websites, each of which is provided by Deloitte Touche Tohmatsu Limited (“DTTL”) or one of its independent member firms or their related entities (collectively, the “Deloitte Network”). To learn more about DTTL, the member firms of DTTL and their related entities, please see About Deloitte.
This privacy statement also contains information about when we share your personal data with other members of the Deloitte Network and other third parties (for example, our service providers).
In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.
About other areas of deloitte.com
Please note that the other country and regional websites contained within deloitte.com are provided by other entities within the Deloitte Network and are not provided by us. Such websites, as well as other websites that may be linked to this Website, are not governed by this privacy statement. We encourage visitors to review the privacy statements on each of these other websites before disclosing any personal information.
Data Controller or Data Processor?
For some services and assignments, we will typically be considered Data Controllers, such as audit services, tax services and other qualified assignments where our clients cannot instruct us in what to do and how we will perform the assignment. For other services and assignments, we will be Data Processors, as for accounting and pay roll- services, staffing assignments and certain consultancy services. You can read more about our roles in different service and assignments here.
What information we collect?
We only collect personal data that is necessary and relevant for the performance of our services, as we need access to certain personal data in order to perform assignments in accordance with the scope. You can read more about our business areas' various personal data processing and for what purposes they need your personal information here.
We may collect personal data from you when you either use this Website because you give it to us (for example in a form on our Website), because other people give your personal data to us (for example your employer or adviser, or third party service providers that we use to help operate our business) or because it is publicly available.
The personal data that we collect or obtain may include your name; age; date of birth; gender; e-mail address; home address; country of residence; lifestyle and social circumstances (for example, your pastimes); family circumstances (for example, your marital status and dependents); employment and education details (for example, the organization you work for, your job title and your education details); financial and tax-related information (for example your income and tax residency); your postings on any blogs, forums, wikis and any other social media applications and services that we provide; your IP address; your browser type and language; your access times; complaint details; details of how you use our products and services; details of how you like to interact with us and other similar information.
The personal data we collect may also include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your dietary requirements (for example, where Deloitte would like to provide you with lunch during a meeting), health (for example, so that we can make reasonable accommodations for you in our buildings, products and services) and sexual orientation (for example if you provide us with details of your spouse or partner).
The types of personal data and special categories of personal data that we collect may vary depending on the nature of the services that we provide to you or our client, or how you use our Website. In some rare circumstances, we might also gather other special categories of personal data about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.
Where we are provided with personal data about you by our client, we take steps to ensure that the client has complied with the privacy laws and regulations relevant to that information; this may include, for example, that the client has provided you with notice of the collection (and other matters) and has obtained any necessary consent for us to process that information as described in this privacy statement.
We understand the importance of protecting children's privacy. Our Website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.
How we use information about you?
Use of personal information to provide services to our clients:
We will use your personal data to provide you or our client with services. As part of this, we may use your personal data in the course of correspondence relating to the services. Such correspondence may be with you, our client, other members of the Deloitte Network, our service providers or competent authorities. We may also use your personal data to conduct due diligence checks relating to the services.
Because we provide a wide range of services to our clients, the way we use personal data in relation to our services also varies. For example, we might use personal data:
- about a client’s employees to help those employees manage their tax affairs when working overseas
- about a client’s employees and customers in the course of conducting an audit (or similar activity) for a client
- about a client to help him/her complete a tax return.
Use of personal information for other activities that form part of the operation of our business
We may also use your personal data for the purposes of, or in connection with:
- applicable legal or regulatory requirements
- requests and communications from competent authorities
- client account opening and other administrative purposes
- financial accounting, invoicing and risk analysis purposes
- client relationship purposes, which may involve: (i) sending you
- thought leadership or details of our products and services that we
- think might be of interest to you; (ii) contacting you to receive
- feedback on services; and (iii) contacting you for other market or
- research purposes;
- recruitment and business development purposes (for example
- testimonials from a client’s employees may be used as part of our
- recruitment and business development materials with that employee’s permission)
- services we receive from our professional advisors, such as
- lawyers, accountants and consultants
- protecting our rights and those of our clients.
Use of personal information collected via our Website
In addition to the purposes connected to the operation of our business above, we may also use your personal data collected via our Website:
- to manage and improve our Website
- to tailor the content of our Website to provide you with a more personalised experience and draw your attention to information about our products and services that may be of interest to you
- to manage and respond to any request you submit through our Website.
Additional information of how we use data about you and why can be found here.
The legal grounds we use for processing personal information
The legal basis for processing personal data varies depending on our services and assignments. If we have a statutory obligation to perform certain tasks, such as audit assignments, the legal basis for processing is our legal obligation. For other types of advisory assignments, the legal basis for processing is our legitimate interest, as otherwise, the assignment cannot be fully executed according to the mission statement and our commitment. An exhaustive processing of all types of information, including personal data, is required for the execution of the assignment. We make an assessment of what personal data is necessary in each case. You can read more about our business areas' different processing of personal data and the legal basis for these here.
Who we disclose your information to?
We are part of a network of member firms worldwide. For the performance of our assignments, transfer of personal data to another member company or other party, such as the authorities, may be made if necessary for the performance of the assignment. We may also transfer your personal data to other member firms in order to convey information to you that may be of interest and to conduct market or other investigations. Personal data may also be transferred to other member firms and third parties in order to respond to your requests, as part of a business transaction such as a sale, reorganization, merged or acquisitions, or where these parties handle information on our mission. You can read more about our business areas' different transfers of personal data here.
Our Website hosts various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Importantly, any personal information that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute to any Social Media Applications will be handled in accordance with this privacy statement.
Please note that some of the recipients of your personal data referenced above may be based in countries outside of the European Union whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal data that comply with our legal obligations. Where the recipient is not a member of the Deloitte Network, the adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal data to third countries. We are awaiting binding corporate rules to be approved by the UK Information Commissioners Office (ICO).
We may also need to disclose your personal data if required to do so by law, a regulator or during legal proceedings.
We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.
Further details of the transfers described above and the adequate safeguards used by Deloitte in respect of such transfers (including copies of relevant agreements) are also available from us by contacting email@example.com.
Protection of your personal information
We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. These measures include:
- education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data
- administrative and technical controls to restrict access to personal data on a ‘need to know’ basis
- technological security measures, including fire walls, encryption and anti-virus software
- physical security measures, such as staff security passes to access our premises.
Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.
In case of a data breach, we have special measures set to limit the risk of information dissemination. We will of course follow the guidelines and requirements specified by the regulatory authority for incident reporting.
How long we keep your information for?
We will hold your personal data on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity or services; (ii) any retention period that is required by law; (iii) the end of the period in which litigation or investigations might arise in respect of the services. Further details of the retention periods with respect to the different business lines are available here.
You have various rights in relation to your personal data. In particular, you have a right to:
- obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you
- ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete
- ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data
- withdraw consent to our processing of your personal data (to the extent such processing is based on consent)
- receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract
- object to our processing of your personal data
In cases where we are a data controller, you can claim these rights directly from us. If we are data processors, you should contact the data controller whom we receive your personal information from instead, in order to exercise your rights.
The information we process within the scope of the assignment may be subject to statutory professional secrecy, which means that we are restricted from disclosing such information. In addition, we are obliged to document completed audit assignments and keep the documentation for at least ten years from the end of the calendar year when the review was terminated, which means that it is not permitted to change / delete personal data contained in such documentation. For those reasons, it is not always possible for us, at the request of a registered person, to limit or restrict any processing of personal data in our assignments.
Processing of personal data for marketing and similar purposes, you are entitled to request deletion, rectification, restriction and objection to such measures of your personal data.
You have a right to complain to the EU Data Protection Authority (“DPA”) in your jurisdiction, which for Sweden is Datainspektionen.
Changes to this privacy statement and effect
We may modify or amend this privacy statement from time to time.
To let you know when we make changes to this privacy statement, we will amend the revision date here. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.
This policy has enterd into effect 7th December 2011, and has been udated 21st May 2012, 20th of March 2014, 26th October 2017 and 17th May 2018.
Questions and Contact
If you have any questions, or if you want to exercise your rigth’s as a registered data subject, please contact us at firstname.lastname@example.org.
113 79 Stockholm
Besöksadress: Rehnsgatan 11
Tel: +46 75 246 10 00